Title: T & E Species Issue
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Permanent Link: http://ufdc.ufl.edu/WL00001911/00001
 Material Information
Title: T & E Species Issue
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: T & E Species Issue, To: Robert Higgins From: David Fisk, November 7, 1995
General Note: Box 9, Folder 14 ( SF-WMD REview Commission - 1995-1996 ), Item 8
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00001911
Volume ID: VID00001
Source Institution: Levin College of Law, University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text
11-07-1995 04:36PM FROM


November 7, 995 IM_ I-- P- 10:55 AM
Prom Fax

Name: David W. Fisk Name: Mr. Robert W. HIgg5i

Company. Suwannee River WMD Company: Higgins Engineering, Inc.

Phone: (904)362-1001 Phone: (407) 439-7807

Fa: (904) 362-1056 Fax: (407) 439-0026


Total number of pages, including cover: 1
Mesas8e
Bob Higgins
Buddy Blain

RE: Water Management District Review Commission T&E Species Issue

I just wanted to drop you a quick note in case L am not ablt to talk with you before the review
commission meeting. l'm In a Board meeting today and on the road tomorrow try to page me
at 1-800-373-4389 after noon tomorrow and ll try to get back with you.

There is a pretty good chance that the E&T species issue of deleting language in ss373.414(2)(b)
may resurface at the next Comnmisfon meeting later this week. No one would like to get this
fixed in Ch. 373 more than me but I suggest extreme caution.

The suggestion to simply delete as.373.414(2)(b) leaves us with an impossible mission just ead
s.373.414(2) as though (b) did not exist ss.373.414(2Xa) would then require the establishment of
size thresholds for isolated wedands "based on biological and hydrological evidence that shows
the fiah and wildlife values of such areas to be minimal". Without the current provision in
ss.(2)b) to treat isolated wetlands differently if E&T species are involved, .e. a different
threshold, am convinced we will not be able to count on and biological or hydrologcal
evidence in setting any threshold e., if B&T are not treated arately, fDol will argue that
any isolated wetland might supot E&T species and thmerfore values are mom than
minimal. As one who lived through the original rule adoption after Booe screwed-up the
statute in the first place I am convinced we will loce ground again TE RESULT IS LUIKLY
TO BE A ZERO THRESHOLD AND A LOSS OF T 0.5 ACRE THRESHOLD WE HAVE NOW.

At a minimum, this change would re-open rulemaking on this issue and I'm not sure anyone
really want that. I don't want you to think rm crying wolf but we need to be very careful
with this stuff and not create a requirement that backfires on everyone.


Dave Fisk



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11-08-1995 11:38AmM FROM TO 918132280340 P.02








SUCTION 373..414 (2)


(2) The governing board or the department is authorized to

establish by rule specific permitting criteria in a!aAiticn tc th

er e- itr. i i&, thisn part which provides-+

-a)- One or more size thresholds of isolated wetlands below

which impacts on fish and wildlife and their habitats will not be

considered. These thresholds shall be based on biological and

hydrological evident"

that shows the fish and wildlife values of such areas to

be minimal.

(b) -Criteria for t"a pnStcction cf threatened and endangered

zpaezioo---in isolated wetlands regardieos of -inc and land usa.





918132280340


0 HIGGINS ENGINEERING, INC.

TELECOMMUNICATION COVER PAGE


TO:


NAME OF FIRM:


TELEPHONE NO.:


FROM:


NUMBER OF PAGES:


(INCLUDING COVER PAGE)


DATE SENT:


REGARDING


PROJECT: c^


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MESSAGE:


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29 R-oI4^.


TELEPHONE NO:
TELECOPIER NO:


(407) 439 7807
(407) 439 0026


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TIME:


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